The Massachusetts Supreme Judicial Court has affirmed a lower court's denial of relief to property owner Penny A. Jean in a complex property development dispute that began in 2021. The case, *Jean v. Salamone*, involved allegations that Jean attempted to withdraw from a joint venture agreement after her business partners had invested significant funds in the project.
The dispute originated when respondents Michael Salamone and another party filed suit against Jean in Superior Court for breach of contract and related claims. According to court documents, the respondents alleged they had entered into a joint venture agreement with Jean to subdivide her residential property, develop and sell the subdivided lots, and split the proceeds.
The complaint alleged that Jean attempted to back out of the agreement approximately one year after its execution, despite the respondents having spent significant money on the development project. This allegation formed the basis for the breach of contract lawsuit that would span several years.
On Jan. 12, 2022, a Superior Court judge granted the respondents' motion for summary judgment in part, ruling that the joint venture agreement was "an effective and binding agreement" and that Jean had breached her obligations under its terms. However, the judge determined that a trial was necessary to resolve the respondents' claims for specific performance and injunctive relief.
Before the matter proceeded to trial, the parties reached a settlement agreement, and an agreement for judgment was entered on the court docket. This settlement appeared to resolve the initial dispute, but compliance issues soon emerged.
In July 2024, the respondents filed a complaint for contempt, alleging that Jean was refusing to comply with the terms of the agreement for judgment. The contempt proceedings resulted in a court order entered Jan. 15, 2025, finding Jean in contempt and ordering her to take specific steps to comply with the agreement for judgment.
Rather than comply with the contempt order, Jean filed a petition seeking relief from the various rulings in the case. Acting as her own attorney, Jean filed a document titled "PETITION FOR REDRESS / MOTIONS AND DEMANDS" in the county court, seeking to overturn the Superior Court's rulings.
A single justice of the Massachusetts Supreme Judicial Court denied Jean's petition for relief. Jean then appealed that denial to the full Supreme Judicial Court, which heard the matter and issued its decision on Dec. 12, 2025.
In affirming the denial of relief, the Supreme Judicial Court upheld the lower court's handling of the case. The court's decision validates the original Superior Court's determination that the joint venture agreement was binding and that Jean had breached her obligations under the contract.
The case illustrates the legal principle that parties cannot simply withdraw from binding contracts after the other party has performed or invested resources in reliance on the agreement. The respondents' investment of significant funds in the property development project created obligations that Jean could not unilaterally terminate.
The Supreme Judicial Court's affirmance also reinforces that settlement agreements, once entered as judgments, carry the full force of court orders. When Jean failed to comply with the agreement for judgment, the court appropriately found her in contempt and ordered compliance.
The decision highlights the importance of carefully considering contract obligations before execution, particularly in real estate development ventures where substantial investments are typically required. Property owners who enter into joint venture agreements for development projects should understand that backing out after partners have invested funds can result in breach of contract liability.
For real estate practitioners, the case serves as a reminder that joint venture agreements for property development must be drafted with clear terms regarding each party's obligations and the consequences of non-performance. The case also demonstrates that courts will enforce these agreements when one party attempts to withdraw after the other has performed.
The ruling represents a victory for the respondents, who successfully argued that Jean's attempt to withdraw from the joint venture agreement constituted a material breach. Their persistence through multiple court proceedings, including the contempt action, ultimately resulted in a favorable outcome.
Jean's decision to represent herself in the later stages of the litigation may have complicated her legal position. The case underscores the challenges faced by pro se litigants in complex commercial disputes, particularly when seeking extraordinary relief from established court rulings.
The Supreme Judicial Court's affirmance brings finality to a dispute that has persisted for nearly four years, from the initial 2021 lawsuit through the 2025 appeal. The decision reinforces that parties must honor their contractual commitments, particularly in business relationships involving substantial investments and reliance by other parties.